20 January 2020

GOC Draft Strategic Plan 2020-27

We have responded to a consultation on the General Optical Council's (GOC) draft strategic plan 2020-27.

Mission, vision and values

4. Thinking about our mission statement, do you agree with the current wording with a focus on ‘continuously’ raising standards’? 

We agree that raising standards will help protecting the public, but would also like to see in the mission a focus on education and on support for optical professionals. 

While we welcome the focus on raising standards, it is important not to chase continual change at the expense of upholding current standards.

5. Thinking about our vision, what does excellent customer service look like to you? 

The GOC’s “customers” need to be defined, as excellent customer service will be different for each stakeholder group. 

We believe these customers include the registrants, optical businesses, employers, education providers, CPD providers, professional bodies, members of the public submitting a complaint, registrants who are under investigation and other UK government agencies. More broadly the GOC’s customers ultimately include every member of the public who seeks optical services and any company providing goods, services and innovation to the UK optical market. A growing number of industry stakeholders work outside the currently regulatory framework, but nonetheless have great influence on the practice of registrants performing protected functions and optical businesses. The GOC should consider how it can work with such stakeholders. Examples would be software providers, imaging manufacturers, lens manufacturers and contact lens manufacturers.

Excellent customer service would involve ensuring that the GOC are efficient and timely in responding, proactive, transparent, supportive, and with a principal aim to meet stakeholders’ needs. The GOC’s activities should facilitate all stakeholders to deliver and support world class eye care, safely and in the best interests of the public which the GOC serve. 

Overall this vision seems very organisationally focused: we would like it to reflect the benefits that the GOC can bring about through fair, supportive and effective regulation and development of standards. Excellent customer service should be an output, but not an outcome. It should be part of a focus for the GOC to strengthen the confidence of key stakeholders in its activities.

6. Thinking about our five values, what types of behaviour or actions would you like to see the GOC demonstrate to meet these values? Please give examples where possible. 


7. To what extent to you agree or disagree that our mission, vision and values are clear? 

Neither agree nor disagree

New challenges and opportunities

8. Are there any other external influences that might affect our work?


The focus on education, technological development, multi-disciplinary approaches and changes to working practices is most welcome as these have a significant impact on eye care. However, we feel that the public perceptions of the optical sector should be also acknowledged as an important external influence. We know that many members of the public often view optometry as a retail rather than a healthcare profession. It is important the public have an understanding of the important roles of optical professionals in maintaining good eye health and vision, and the services available to them.

We would also like the GOC to acknowledge the impact of changes in the economic environment on its key stakeholders.

Looking Forward

9. To what extent to you agree or disagree with our three strategic objectives: world class regulatory practice; improved customer service; and continuous improvement?

World class regulatory practice 

Improved customer service 

Continuous improvement 

10. To what extent do you agree or disagree with our aims under each of the three strategic objectives?

World class regulatory practice  

Improved customer service 

Continuous improvement 

11. Are there any other aims you think we should consider including under our strategic objectives? 

We would like to see the aim for World-class Regulatory Practice to be strengthened.

We welcome the implicit acknowledgment within the draft strategy of the need to modernise to ensure the GOC is up-to-date in how it fulfils its functions. This should be strengthened and be more specific about how the GOC will reflect wider regulatory developments. This includes a proactive approach to professionalism, the use and analysis of data to understand trends and needs and inform strategic priorities, and engagement with multi-professional agendas.

We would like to see a specific focus on professionalism added to this strategic objective since this is the focus of the Westminster government’s regulatory reform agenda.  

We also suggest adding a reference to reviewing and appraising the GOC’s role after registration. We know other regulators are actively engaging in the implications of government workforce transformation agendas, such as advanced practice and more flexible role configurations across professions, and the potential value of credentialing.  

There also needs to be a recognition of the need to achieve a safe transition in implementing the Education Strategic Review (ESR), particularly in terms of ensuring patient safety, stability in education provision and security of workforce supply. It will also be important to evaluate the impact of the changes brought about by the ESR.

Within the focus on CPD/CET, there needs to be better clarity on the GOC’s approach. The GOC also needs to clarify its expectations of registrants’ professionalism and their accountability and responsibility for their decisions and actions. We would also like to see a shift to recognising and respecting registrants’ evolving scope of practice.

Within the aim of Continuous Improvement, we would like to see an additional focus on data, particularly strengthening data collection and analysis to enable more effective regulation. This data should also be accessible where it can help other bodies answer questions about workforce supply and better help them meet patient need and improve service delivery. For example, the GOC can add value by analysing POLAR4 information for optometry entry to universities and therefore entry to the profession. This would help monitor geographic variation in registrants per head of population at country level.

12. How can we better involve patients/public in our work? 

We believe the GOC is rightly engaging with patients and the public, e.g. through consultations and surveys. 

The GOC should ensure it is engaging with patients and the public in an accessible way, to better involve members of the public who may need more support to access services and contribute to setting standards. 

Defining KPIs for each of these stakeholder groups, agreed in advance and set for the term of the strategic plan, would also help better engage patients/public in your work.

What will success look like?

13. To what extent do you agree or disagree with our measures for success? 


14. Is there anything else you think we should include? 

The third success measure on page 8 focuses on retaining the confidence of the professions the GOC regulates. We believe that there is a need to strengthen stakeholders’ confidence in the GOC. We suggest amending this outcome to reflect the need to strengthen the confidence of key stakeholders, including education providers, employers and professional bodies.

Equality, diversity and inclusion

15. How can we better promote equality, diversity and inclusion in our work? 

The GOC should ensure that a new CPD framework does not indirectly discriminate any groups of practitioners, for example by ensuring there is not an unreasonable burden on registrants to complete CPD outside working hours, to the detriment of registrants’ wellbeing.

16. Do you have any further comments on anything in our draft strategic plan? 

We support the proposal to introduce more flexibility and encourage more reflection by registrations as well as the aim to focus learning on individuals’ scope of practice. We would like to know more details as soon as they are available, particularly where reforms will be phased in during the current CET cycle. This will enable us to target our CPD and CET offer to members to meet these new developments.


Submitted: January 2020

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